On February 6, 2019, the Physician Clinical Registry Coalition participated in a “white boarding” session with officials from the Centers for Medicare and Medicaid Services (CMS), the Council for Medical Specialty Societies (CMSS), and PCPI. The session focused on improving the qualified clinical data registry (QCDR) measure review process, licensing and harmonization of QCDR measures, and other issues impacting QCDR participation in the Merit-based Incentive Payment System (MIPS).
The session came at a key time as CMS embarks on drafting the Quality Payment Program proposed rule for CY 2020. The Coalition participated in this session as a part of its ongoing dialogue with CMS about the QCDR program and QCDR participation in MIPS. The Coalition submitted a letter to CMS in December 2018 that identified many of the issues discussed in the white boarding session. The full letter is available here. The Coalition also advocated for solutions to many of these issues in its comments on the CY 2019 Physician Fee Schedule and Quality Payment Program proposed rule. The Coalition’s comments are available here.
As a result of the Coalition’s advocacy efforts on the CY 2019 Physician Fee Schedule and Quality Payment Program proposed rule, CMS decided not to adopt its proposed mandatory QCDR measure licensing requirement. The proposal would have taken away QCDRs’ ability to ensure that only qualified third parties can use their measures and that their measures are used appropriately, as well as threatened the intellectual property rights of measure owners. The Coalition applauds CMS’s decision not to adopt this proposal. The Coalition will continue to work with CMS to develop ways to preserve the intellectual property rights of QCDR measure owners, while ensuring that measures are readily available to other qualified QCDRs.